Sanctions Policy

Purpose:  Pride & Pinion has a strict sanctions compliance policy to ensure we do not conduct business with sanctioned individuals, entities, or countries. Given the international reach of our online Shopify store (with worldwide shipping offered), it is critical that we adhere to all applicable trade sanctions and export controls. This policy outlines how we screen transactions and shipments against sanctions lists and restricted regions, and the procedures in place to prevent any dealings that would violate UK, US, or international sanctions.

Avoidance of Sanctioned Jurisdictions:  We will not ship or sell to customers in countries that are under comprehensive international sanctions or that present high risk. Our shipping carrier is FedEx for international deliveries, and FedEx itself does not service certain sanctioned countries (for example, Iran is not served by FedEx deliveries). 

In addition, Pride & Pinion proactively blocks transactions involving the following locations:

Countries under U.N., UK, or U.S. embargoes: e.g., Iran, North Korea, Syria, and Cuba (no sales or shipments can be made to these countries).
Conflict or high-risk regions: e.g., Iraq (due to regional sanctions and instability, we do not ship watches to Iraq), and Russia (all shipments to Russia are suspended in line with UK/EU/US sanctions following the Ukraine conflict).
High-Fraud or Restricted Areas: e.g., most of South America. Note: While South American countries are not generally subject to international sanctions, we have made a business decision to restrict shipments to many South American destinations due to elevated fraud risk and customs issues. This includes blocking orders or shipments to certain countries in that region (we assess on a case-by-case basis, with many destinations in South America currently not supported). Customers from these regions may be declined at checkout or asked for additional verification and approval from management.

The above list is not exhaustive. Pride & Pinion maintains an internal list of “Do Not Ship” countries, which is regularly updated based on the latest sanctions and risk information. If a customer attempts to order from a blocked country, our website or team will prevent the transaction from completing and inform the customer that we cannot fulfil the order to that destination.

Sanctions Screening Procedure:  For every new order or customer, especially those with international shipping addresses, we perform a sanctions screening as part of our review:

Customer and Payment Screening: We manually screen the customer’s name, shipping address, and any known business affiliations against the major international sanctions lists. The primary lists we consult are the UK HM Treasury sanctions list (UK Sanctions List maintained by the Office of Financial Sanctions Implementation), the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list, and the United Nations Security Council sanctions list. These sources cover designated persons, organizations, and prohibited parties globally. We ensure our screening information is up-to-date; updates to these lists are monitored regularly.
Automated Checks: Currently, our sanctions checks are conducted manually by referencing publicly available databases and government resources. We are evaluating automated screening tools to cross-check customers against sanctions databases in real-time for additional assurance. In the meantime, our staff uses the latest published lists and, if needed, online lookup tools provided by governments for searching names.
High-Risk Flags: If a customer’s name or address matches or closely resembles an entry on a sanctions list, or if the order involves a bank from a sanctioned country, the transaction is halted. The compliance team (Managing Director or designated compliance officer) will investigate further to confirm if it is a true match (for example, comparing date of birth or middle names if available). The order will remain on hold during this investigation. No product will be shipped until the screening is cleared.
Record-Keeping: We keep a record of sanctions screenings for high-value and international transactions, noting the date of check and outcome. This audit trail ensures we can demonstrate compliance to Shopify or regulators if required, showing that we screened the relevant parties before proceeding.

International Shipping Controls:  All international shipments are processed through trusted couriers (primarily FedEx, and UPS or DHL in certain cases). These couriers themselves enforce shipping restrictions to sanctioned destinations, which provides an additional layer of control. For example, FedEx will not carry goods to countries like North Korea or Iran, and has suspended services to Russia as of 2022 due to sanctions. Pride & Pinion’s policy is to ship only to countries and regions where such services are permitted.

Additionally:

We insure and track every shipment. If a package’s destination is flagged by our courier as restricted or embargoed, we will immediately cancel the shipment and refund the transaction (unless an alternate address in a permitted country can be arranged by the customer, subject to screening).
We include a requirement for ID upon delivery or pickup for high-value international shipments. As noted in our Shipping Policy, if you purchase from outside the UK/Ireland, we ship to your nearest FedEx/UPS collection point and the recipient must show ID to collect. This helps ensure the item isn’t rerouted to a sanctioned party and that the person picking up is the legitimate customer.

Responsibility and Monitoring:  The Managing Director (Stephen Davidson) is responsible for monitoring updates to sanctions programmes and ensuring our team is informed. We subscribe to HM Treasury and OFAC update notifications so that new sanctions (such as newly listed individuals or entities) can be integrated into our screening process promptly. Stephen Davidson or an appointed compliance manager will update the internal “Do Not Ship” list immediately if a new country or region becomes sanctioned or high-risk. All staff involved in processing orders are trained to be aware of sanctions compliance – they know to check the destination country against our blocked list and to escalate any potential match on a sanctions list to management. We conduct a periodic audit (at least quarterly) of recent transactions and new customers to confirm that sanctions screening was performed and documented.

Escalation Procedure:  If any team member identifies a possible sanctions issue (e.g., a customer from a high-risk country not explicitly blocked by the system, or a name match on a sanctions list), they must pause the transaction and alert the Managing Director immediately. Under no circumstances will the order be completed or the item shipped until clearance is given. The Managing Director will review the case, which may involve consulting external legal counsel or compliance experts if needed. If it is confirmed that the customer or transaction is sanctioned or too high-risk, the order will be cancelled. If there is a false match (a customer has a similar name to a sanctioned individual but is verified as different), we will document the due diligence we performed and proceed with caution or additional safeguards.

Compliance with Laws:  This Sanctions Policy ensures Pride & Pinion’s operations are in line with UK sanctions law and international requirements. We understand that non-compliance can lead to severe penalties and reputational damage. Therefore, we take a conservative approach: when in doubt, we will err on the side of caution and decline a transaction rather than risk a sanctions breach. Our policy also aligns with Shopify’s expectations for high-risk merchants to have robust controls in place. Pride & Pinion will cooperate with any official inquiries regarding sanctions and will report any sanctions violations to the proper authorities.

Review:  The Sanctions Policy is reviewed at least annually and whenever there are major geopolitical developments that could affect sanctions (for instance, new international conflicts or new regulations). Updates will be made to reflect any changes in the lists of sanctioned countries or entities. All staff will be informed of significant changes to ensure ongoing compliance. By adhering to this policy, Pride & Pinion upholds international law and ethical standards, ensuring that our luxury watch business is not used to fund or facilitate prohibited activities.